Tax

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Finland: Group tax deduction for cross-border tax losses - new rules - Taxand
taxand.com Nov 20, 2020
The Finnish Government has recently issued a proposal for new legislation concerning the tax deductibility of cross-border tax losses. The proposed legislation would allow the so-called final losses of a subsidiary located in the EU/EEA member...
First Look: US Tax Court rules in favor IRS in Coca-Cola transfer pricing dispute
mnetax.com Nov 19, 2020
At issue was the intercompany royalties due to Coca-Cola from its foreign affiliates for the use of US owned intangible assets. On account of this dispute, the IRS increased the beverage company’s taxable income by about $9.6 billion for 2007–2009.
Transfer Pricing Do's and Don'ts in the current market - Taxand
taxand.com Nov 19, 2020
As companies prepare to bring 2020 to a financial close and look to secure financial stability across their organisation, they are presented with transfer pricing challenges due to economic uncertainties brought about by the COVID-19 pandemic. It’s...
Cross-border tax disputes continued to rise in 2019, new OECD stats say
mnetax.com Nov 19, 2020
Despite the efforts of the OECD and others enhance tax certainty, the number of new tax disputes between multinational groups and governments continued to increase in 2019, according to the OECD’s latest statistics, released today. In 2019, the...
Blackrock prevails in UK transfer pricing dispute
mnetax.com Nov 18, 2020
US-headquartered Blackrock investment management group, on 3 November, won its appeal against the UK tax authority’s denial of deductions for interest paid on US$4 billion of loan notes, issued as part of its 2009 deal to acquire Barclays Global...
Webinar: Details of the Blueprints – the OECD’s proposal on the taxation of the digital economy
taxand.com Nov 18, 2020
Since the conclusion of the BEPS project in 2015, the OECD has been trying to revise and reform international taxation principles with a view to address the challenges of the digital economy. After months of technical work and negotiations, the...
First Look: US and Mexico renew of competent authority agreement on Maquiladoras
mnetax.com Nov 17, 2020
The US IRS on November 16 announced that the US and Mexico have agreed to renew their transfer pricing framework for US multinational enterprises that have maquiladora operations in Mexico. The agreement allows a US taxpayer to avoid double...
China signed 21 advance pricing arrangements in 2019, report shows
mnetax.com Nov 17, 2020
China’s State Taxation Administration, on 29 October, published the 2019 Advance Pricing Arrangement Annual Report, providing statistics on advance pricing arrangements signed between taxpayers and the China State Taxation Administration from 2005...
Swiss government approves protocols to Liechtenstein, Malta, Cyprus tax treaties
mnetax.com Nov 13, 2020
Switzerland’s Federal Council, at its November 11 meeting, approved protocols to its existing bilateral tax treaties with Liechtenstein, Malta, and Cyprus. The amendments add a ‘main purpose clause’ to each tax treaty, designed to prevent a form of...
Good Morning SEE webinar series part 3: Brexit - changes to VAT
taxand.com Nov 12, 2020
The third in LeitnerLeitner Taxand’s new Good Morning SEE webinar series. Our tax experts from Slovenia, Croatia and Serbia provide some insight into VAT changes due to Brexit. The United Kingdom has left the EU and on 1 February 2020 became a...
News
taxand.com Nov 12, 2020
A recent ruling on 1 November 2020 by the Haifa District Court in the tax appeal of Beit Hossen Ltd. and its shareholders may change dramatically the taxation of share redemption transactions in Israel. The Beit Hossen Ruling constitutes a...
Uranium transfer pricing and Cameco’s battle with Canada
mnetax.com Nov 11, 2020
The Canada Revenue Agency filed an appeal to the Supreme Court of Canada on October 30, seeking to overturn its loss in the Federal Court of Appeal in its transfer pricing dispute with Cameco, as reported by Warren Novis in his recent MNE Tax...
Swiss government approves new law governing tax treaties
mnetax.com Nov 11, 2020
Switzerland’s Federal Council, during its meeting on 4 November, agreed to significant amendments to the laws relating to tax treaties. The new legislation would apply provided the applicable tax treaty does not contain any deviating provisions....
UN to add automated digital services article to model tax treaty
mnetax.com Nov 10, 2020
The UN Committee of Experts on International Cooperation in Tax Matters has agreed to add a new, optional, article to the UN model tax treaty that would grant additional taxing rights to countries where an automated digital services provider’s...
Panama becomes 56th nation to finalize MLI
mnetax.com Nov 5, 2020
Panama has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ( MLI), the OECD today announced. The document will amend Panama’s existing,...
Canada Revenue appeals long-running transfer pricing dispute loss to Supreme Court
mnetax.com Nov 3, 2020
The Canada Revenue Agency (CRA) has filed an appeal in the Supreme Court of Canada seeking to overturn its June 26 loss in the Federal Court of Appeal in its transfer pricing dispute with Cameco. Cameco received notice of the appeal on October 30,...
OECD releases new methodology for peer review of country-by-country reporting minimum standard
mnetax.com Oct 29, 2020
The OECD today released a new methodology for judging whether 137 countries and their tax administrations have met minimum standards on country-by-country reporting for large multinational businesses. The country-by-reporting standards were agreed...
Ireland releases tax bill, announces plan to enact interest deduction limits from 2022
mnetax.com Oct 29, 2020
On 22 October, the Irish government published Finance Bill 2020, which contains legislation to enact tax measures. The tax bill includes several provisions affecting multinational enterprises with operations in Ireland. The release of the tax bill...
Croatia to initiate tax treaty negotiations with the United States
mnetax.com Oct 28, 2020
The government of the Republic of Croatia, on September 30, adopted a decision to initiate proceedings to conclude a convention with the United States on the avoidance of double taxation and the prevention of tax evasion with respect to taxes on...
Denmark courts reject tax authority’s formalistic transfer pricing approach
mnetax.com Oct 28, 2020
In a string of cases decided over the past two years, Denmark’s Supreme Court and high courts have ruled against the tax administration’s formalistic approach to transfer pricing, the most recent example being the July 2 Western High Court ruling...
EU Commission work programme reveals plan for new taxes
mnetax.com Oct 26, 2020
On 19 October, the EU Commission announced its Work Programme 2021, hopefully titled “A Union of vitality in a world of fragility.” Aware of the hard times due to the COVID-19 pandemic, the EU seeks to arise stronger than ever before, introducing...
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